Page 1 of 6 

Responses to SCA-TR-2021-SP001, 

Revision 0, Review of 2019–2020 Revisions 

to Rocky Flats Plant Technical Basis 

Documents

Response Paper

National Institute for Occupational 

Safety and Health

July 22, 2022

Mutty M. Sharfi 

Oak Ridge Associated Universities Team

Reviewed by LaVon B. Rutherford 

Division of Compensation Analysis and Support 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Response Paper Responses to SCA-TR-2021-SP001, Revision 0, Review of 2019–2020 

Revisions to Rocky Flats Plant Technical Basis Documents

July 22, 2022

Page 2 of 6 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

ORAUT-TKBS-0011-2, ROCKY FLATS PLANT – SITE DESCRIPTION

Section 3.1.1 – SC&A (2005) Finding 8, Section 5.4.1 – Inadequate Information Regarding 

Recycled Uranium

On the basis of its acknowledgement and treatment in TBD [technical basis 

document]-5, SC&A recommends closure of this issue from a substantive 

standpoint. However, SC&A also recommends that, for consistency, TBD-2, 

revision 02, be revised to reflect this understanding [SC&A 2021, p. 10]. 

NIOSH Response:

To be more consistent with the text in ORAUT-TKBS-0011-5, Rocky Flats Plant – Occupational 

Internal Dose [Oak Ridge Associated Universities (ORAU) Team (ORAUT) 2020b], edits to

ORAUT-TKBS-0011-2, Rocky Flats Plant – Site Description [ORAUT 2020a], to point out that 

recycled uranium could have been at Rocky Flats Plant (RFP) starting in 1952 will be done in 

future revisions. 

ORAUT-TKBS-0011-3, ROCKY FLATS PLANT – OCCUPATIONAL MEDICAL DOSE

Section 4.2 – General Review of ORAUT-TKBS-0011-3, Revision 03 

SC&A does note that the “Publication Record” on page 2 of revision 03 contains 

incorrect table references for revision 03 (table 3-7 and table A-2 are no longer 

used in this version). Also, the reference to table 3-4 in at the end of the second 

paragraph in section 3.4.2 (p. 10), should be corrected to table 3-3, which has the 

organ dose estimates [SC&A 2021, p. 17]. 

NIOSH Response:

Edits to ORAUT-TKBS-0011-3, Rocky Flats Plant – Occupational Medical Dose [ORAUT 

2019a], to address these errors will be done in future revisions. 

ORAUT-TKBS-0011-5, ROCKY FLATS PLANT – OCCUPATIONAL INTERNAL DOSE

Section 6.2.4 – SC&A (2005) Section 5.2.6.2 – Calibration of Lung Counting to Am-241 

SC&A did find that table B-11, page 104, lacks units for the MDA [minimum 

detectable amount] values; it appears that it should specify the unit of nanocuries

[SC&A 2021, p. 31]. 
Response Paper Responses to SCA-TR-2021-SP001, Revision 0, Review of 2019–2020 

Revisions to Rocky Flats Plant Technical Basis Documents

July 22, 2022

Page 3 of 6 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response:

Edits to ORAUT-TKBS-0011-5 [ORAUT 2020b] to add units for the MDA values will be done 

in future revisions. 

Section 6.3 – TBD Does Not Consider Potential Contribution of Ingestion Pathway 

TBD-5 should include recommendations for ingestion intakes or direct reference 

to the appropriate ingestion-intake-related document. Although this issue has been 

resolved in practice, ingestion intakes should be addressed in TBD-5 with reference 

to OCAS-TIB-009. Therefore, SC&A recommends that this issue remain open until 

appropriate revisions are made in TBD-5 [SC&A 2021, p. 33]. 

NIOSH Response:

TBDs are designed to contain site-specific guidance. The selection of intake pathway (e.g., 

inhalation vs. ingestion) is a generic issue to all sites and is therefore covered in ORAUT-OTIB0060, Internal Dose Reconstruction [ORAUT 2018]. This is done in order to maintain 

consistency in dose assessments across all sites. There is no site-specific scenario that is being 

identified in this finding that would warrant the TBD to provide site-specific guidance. 

Therefore, no changes to ORAUT-TKBS-0011-5 [ORAUT 2020b] are recommended.

ORAUT-TKBS-0011-6, ROCKY FLATS PLANT – OCCUPATIONAL EXTERNAL 

DOSE

Section 7.3.4.1 – Default Neutron Energy Distribution

Observation 1: Different neutron dose multiplier factors need clarification.

The reason for the change in neutron dose multiplier factors listed in table 6-16 of 

revision 03 compared to table 6-14 of revision 00 needs clarification [SC&A 2021, 

p. 50]. 

NIOSH Response:

These numbers were updated based on the guidance in ORAUT-OTIB-0055, Technical Basis for 

Conversion from NCRP Report 38 Neutron Quality Factors to ICRP Publication 60 Radiation 

Weighting Factors for Respective IREP Input Neutron Energy Ranges [ORAUT 2006], which 

was issued after ORAUT-TKBS-0011-6, Rocky Flats Plant – Occupational External Dose, 

Rev. 0 [ORAUT 2004]. 
Response Paper Responses to SCA-TR-2021-SP001, Revision 0, Review of 2019–2020 

Revisions to Rocky Flats Plant Technical Basis Documents

July 22, 2022

Page 4 of 6 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Section 7.3.4.2 – Tables 6-18 and 6-19 of Revision 03 

Observation 2: LOD [limit of detection] values for 1962 and 1963 need 

clarification.

The reason for recommending 226 mrem instead of the calculated value of 369 

mrem in tables 6-18 and 6-19 needs clarification [SC&A 2021, p. 50]. 

NIOSH Response:

The value of 369 mrem provided by SC&A in their finding cannot be reproduced. For 1962 and 

1963, the LOD equation is LOD = Blank + 1.65 × sqrt(Blank). The value of Blank is calculated 

by the equation Blank = 100 × (16/10), which results in 160 mrem. Therefore, the LOD value 

should be 160 + 1.65 × sqrt(160) or 181 mrem. Edits to ORAUT-TKBS-0011-6 [ORAUT 

2019b] to correct the LOD value for 1962 and 1963 in Table 6-18 will be done in future 

revisions. 

Section 7.3.4.3 – LOD Values for 2004 and 2005 

Observation 3: References for LOD values for 2004 and 2005 are needed. 

References for recommending photon, neutron, and beta LOD values for 2004 and 

2005 are needed [SC&A 2021, p. 51]. 

NIOSH Response:

Edits to ORAUT-TKBS-0011-6 [ORAUT 2019b] to provide references for the LOD values for 

2004 and 2005 will be done in future revisions. 

Section 7.3.5 – Missing or Incorrect Information

SC&A found that the following references were used in the text but were not listed 

in the reference section on pages 64–69: 

• Page 10: Sebelius (2013) 

• Page 11: NIOSH (2013) 

• Page 94: NIOSH (2006) 

SC&A found that the caption for table C-8 given in the list of tables at the bottom 

of page 93 should use the phrase “uranium workers” not “plutonium workers,” 

per the actual caption for table C-8 on page 108 [SC&A 2021, p. 51]. 
Response Paper Responses to SCA-TR-2021-SP001, Revision 0, Review of 2019–2020 

Revisions to Rocky Flats Plant Technical Basis Documents

July 22, 2022

Page 5 of 6 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response:

Edits to ORAUT-TKBS-0011-6 [ORAUT 2019b] to correct the references and fix the caption for 

Table C-8 will be done in future revisions. 
Response Paper Responses to SCA-TR-2021-SP001, Revision 0, Review of 2019–2020 

Revisions to Rocky Flats Plant Technical Basis Documents

July 22, 2022

Page 6 of 6 

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

References

NIOSH [2004]. Estimation of ingestion intakes. Cincinnati, OH: U.S. Department of Health and 

Human Services, Centers for Disease Control and Prevention, National Institute for Occupational 

Safety and Health. OCAS-TIB-009 Rev. 0, April 13. [SRDB Ref ID: 22397] 

ORAUT [2004]. Rocky Flats Plant – occupational external dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0011-6 Rev. 00, January 20. [SRDB Ref ID: 

20175] 

ORAUT [2006]. Technical basis for conversion from NCRP Report 38 neutron quality factors to 

ICRP Publication 60 radiation weighting factors for respective IREP input neutron energy 

ranges. Oak Ridge, TN: Oak Ridge Associated Universities Team. ORAUT-OTIB-0055 Rev. 00,

June 5. [SRDB Ref ID: 29980] 

ORAUT [2018]. Internal dose reconstruction. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. ORAUT-OTIB-0060 Rev. 02, April 20. [SRDB Ref ID: 171554] 

ORAUT [2019a]. Rocky Flats Plant – occupational medical dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0011-3 Rev. 03, August 19. [SRDB Ref ID: 

177867] 

ORAUT [2019b]. Rocky Flats Plant – occupational external dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0011-6 Rev. 03, January 14. [SRDB Ref ID: 

175317] 

ORAUT [2020a]. Rocky Flats Plant – site description. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. ORAUT-TKBS-0011-2 Rev. 02, August 20. [SRDB Ref ID: 180380] 

ORAUT [2020b]. Rocky Flats Plant – occupational internal dose. Oak Ridge, TN: Oak Ridge 

Associated Universities Team. ORAUT-TKBS-0011-5 Rev. 04, September 1. [SRDB Ref ID: 

178626] 

SC&A [2021]. Review of 2019–2020 revisions to Rocky Flats Plant technical basis documents. 

Vienna, VA: SC&A Inc. SCA-TR-2021-SP001 Rev. 0, December 3. [SRDB Ref ID: 193211]